10/19/99: EPA HAS TAKEN THREE SEPARATE ADMINISTRATIVE ENFORCEMENT ACTIONS AGAINST HEARTLAND, INCLUDING THE ASSESSMENT OF CIVIL PENALTIES. IN ADDITION, IN 1997, EPA PERFORMED A COMPLIANCE ASSISTANCE AUDIT AT HEARTLAND'S LAGORATORY IN A FURTHER EFFORT TO BRING THE FACILITY INTO COMPLIANCE WITH RCRA. DESPITE THESE REPEATED CONTACTS WITH REGULATORSWHICH INCLUDED BOTH ENFORCEMENT AND COMPLIANCE ASSISTANCE EFFORTS, KDHE INSPECTORS FOUND NUMEROUS VIOLATION S DURING A 1998 INSPECTION OF THE FACILITY. BECAUSE OF HEARTLAND'SHISTORY OF NONCOMPLIANCE, KDHE AND EPA HAS DECIDED THAT A CIVIL JUDICIAL REFERRAL IS APPROPRIATE FOR THE VIOLATIONS DISCUSSED IN THIS REFERRAL. THE EPA HAS WORKED CLOSELY WITH KDHE IN DEVELOPING THIS REFERRAL, AND KDHE AGREES THAT EPA SHOULD REFER THIS MATTER TO THE DEPARTMENT OF JUSTICE.